Richard A. Stasewich - Page 4

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journal, and receipts for expenses. Petitioner had a Certificate
of Registration in the State of Illinois that authorized him to
engage in the business of selling tangible personal property at
retail in Illinois. For 1992 through 1994, petitioner filed
Forms ST-1, Sales and Use Tax Returns, with the Illinois
Department of Revenue. In 1995, petitioner completed Forms W-2,
Wage and Tax Statements, for the art students that he employed.
Petitioner neither kept records of a budget or financial
projections for his artist activity nor kept a record of the
costs that he might incur in attempting to develop his artist
activity.
Prior to 1992, petitioner decided to create a commercially
viable product from his nude drawings. Petitioner tried fashion
illustrations and spent a lot of money on materials and props,
but he never secured a large client and never earned anything
from it.
On or around 1992, petitioner’s artist activities changed
from nude drawings and fashion illustrations to portraitures and
installation art displays. At a cost of about $1,200, he placed
two advertisements in his local newspaper on December 11 and 18,
1992, to solicit work as a commissioned artist of portraits.
Petitioner painted two portraitures between 1992 and 1995 that
generated about $850 in revenue. During 1992 to 1995, petitioner
created four displays of installation art (consisting of peppers,
dolls, pumpkins, and cucumbers) that were displayed in front of